Digital Product Passport Granularity: How to Choose Model, Batch or Item Level

Digital product passport granularity is the level one passport covers: a whole model, one production batch or a single item. For most products, the law sets that level, not you. This guide is for the operator placing goods on the EU market: the brand, importer or manufacturer that must create the Digital Product Passport (DPP).

New to passports? Start with what a digital product passport is.

What is digital product passport granularity?

Digital product passport granularity is the level a passport and its identifier refer to: a model (every unit of one design), a batch (units of one model made in one plant at one time) or an item (one single unit). Each product law or ESPR delegated act sets the level; the data inside may vary at other levels.

Under the ESPR (Ecodesign for Sustainable Products Regulation, (EU) 2024/1781), each delegated act sets the level (Article 9(2)(d)), the unique product identifier follows it (Annex III(b)), and recital 33 gives the batch and item meanings above.

Do this: decide two levels per product family: how finely you number units (identification) and how finely each field varies (data). The field inventory below is the template.

Which level does your law already fix?

Start by looking up the digital product passport granularity your law already sets. The construction "product type" works as model level.

Marking is a separate duty. Products under an ESPR delegated act must bear a type, batch or serial number or another identifying element, even when the passport is model level. Where the product's size or nature does not allow it, the information goes on the packaging or an accompanying document (ESPR Article 27(5)).

Batteries bear a model identification plus a batch or serial number or another identifying element (Article 38(6)), while the passport stays per battery.

Implementing Regulation (EU) 2026/1778 (IR), the registry rules in force since 6 August 2026, adds four rules:

1. Most granular wins. Under two laws with different levels, register at the finest (IR Article 8(3)).
2. Items link upwards. For ESPR products, item passports link to batch and model identifiers, and batch passports to the model identifier, where those exist (Article 8(4)–(5)). You issue those identifiers yourself (recital 14). For batteries the registry form treats them as optional today; build both master records anyway.
3. Unique goods are exempt. Handmade and other products unique by nature need no batch or model identifier (recital 14).
4. The level is checked. The registry checks digital product passport granularity automatically at submission (Article 8(7)(c)). A passport at the wrong level fails.

Today the registry offers only item level, preset for batteries, and no registration can succeed yet (User Guide v1.03, 16 September 2026).

Do this: record your digital product passport granularity per product family: law, level, article and date. Where two laws apply, note the finer level.

How do you choose a level where the law leaves room?

The law sets the passport level. You still decide whether to encode a finer identifier than required, and at which level each field lives. GS1's provisional DPP standard allows batch or serial qualifiers "even if not required by regulation".

For ESPR products still waiting for their act, the same exercise shows which digital product passport granularity to prepare for.

Score each product family on this digital product passport granularity matrix. It builds on the JRC's Annex 7 criteria and GS1's retail examples, plus two rows of our own (legal level, existing traceability):

How to read it. Mark each row M, B or I, then apply four rules in order to reach a digital product passport granularity verdict:

1. Law first. The legal row fixes the level you register; the registry checks it (IR Article 8(7)(c)). You may encode a finer identifier in the code and keep finer internal records, but a finer passport is registered only where another EU law requires it (IR Article 8(3)).
2. Item if two or more of the repair, counterfeiting and life-cycle rows read I and the volume row reads I.
3. Batch if variability or recall precision reads B and the print audit below shows the line already prints variable data.
4. Model otherwise.

Where the law already fixes the level, rules 2–4 decide only what you encode and how you keep records. The JRC warns that item level for cheap mass-produced goods means an enormous number of records that may not pay off.

Write one verdict line per product family:

The hybrid rule: item identity, model-level data. The battery passport is built this way. Annex XIII to Regulation (EU) 2023/1542 lists composition, capacity, dismantling information and test reports as information relating to the battery model; only performance values, state of health, status and use data relate to the individual battery.

So item-level digital product passport granularity does not mean every field is held per unit; the JRC makes the same split (2026 methodology, step C.3, analysis, not law). Record both levels per field:

For a full field list in one product group, see textile DPP data requirements.

Which GS1 identifiers carry each level?

With GS1 identifiers, digital product passport granularity maps onto the GTIN and its qualifiers. GTINs come from a GS1 Company Prefix licensed by a GS1 member organisation.

Rules for your numbering specification:

• Format and order. Lot (AI 10) and serial (AI 21) take up to 20 alphanumeric characters each, always with a GTIN. In the path they run 22 (variant), 10, then 21.
• No repeats per GTIN. Brand owner and manufacturer must keep lot numbers from repeating under one GTIN across sites, and serial numbers from repeating under one GTIN (GS1 General Specifications 26.0, §3.4.1, §3.5.2).
• No reuse. GS1's provisional DPP standard, which is not ratified, bars reusing the whole identifier during the product's life cycle. It lets the same lot or serial values sit under different GTINs.
• Batteries. Its overview lists GTIN plus serial in a QR Code; construction is still "TBD".

The GS1 Digital Link page explains the URI.

Lot-code audit. At batch level, your digital product passport granularity is only as unique as your lot code.

Check that the format is unique per GTIN across every plant and contract manufacturer, and cannot repeat during the product's life. A day-of-year code such as 245 repeats every year; P2-26-245-A (plant, year, day, shift) does not.

Serial-number policy template:

GS1 Support notes that these limits bind only SGTIN-96 tags; SGTIN-198 accepts any GS1 serial. Under the provisional standard, RFID comes only in addition to a QR Code or Data Matrix.

What does a finer level change on the production line?

The finer your digital product passport granularity, the more your printing changes. GS1's 2D retail guideline (release 1.1) describes three routes:

Three effects to plan:

• Bigger symbols. Every added field makes the 2D code larger, and variable data can rule out pre-printing (§5.4).
• Real-time printing. Assess line speed, current printers, substrate and placement before you switch (§5.7.4).
• Durability. Battery QR codes are printed or engraved indelibly on the battery, with packaging and documents as the fallback only (Article 13(7)). Toys carry it on the toy or an affixed label, or on packaging where size or nature requires (Article 19(7)).

Where the carrier must outlive the packaging, choose a line-printed label, a durable label or direct part marking; laser-engraved codes need specialised lighting and vision systems (GS1).

Print audit. Before you encode anything finer than model level, run this per line:

See our 2D barcodes page and the 2D barcode transition roadmap.

What does each level mean for IT and the registry?

Digital product passport granularity multiplies records. Size IT with two lines:

• Passports created per year = units (item), batches (batch) or new models (model) placed on the market that year.
• Records you keep = that figure × years each passport must stay available.

Line A in the hypothetical walkthrough below creates 11,400 item passports a year; if you plan for 10 years of availability, that is 114,000 records to keep.

Availability: toys and detergents 10 years after placing on the market (Articles 19(2)(g), 21(2)(g)); construction at least 10 years (CPR Article 75(2)(i)); batteries until recycled (Article 77(8)); ESPR products per act (Article 11(e)).

Set up six things:

1. Master records. Model and batch records that every item record points to, the IR Article 8(4)–(5) link.
2. Registry route. The IR provides for an API (recital 3), but User Guide v1.03 documents only a one-at-a-time form and file uploads of at most 100 passports (XML or JSON). One bad record rejects every passport in the file: script uploads, validate each file first, and budget for the API once the Commission documents it.
3. Identifier field. The registry's unique product identifier is a URL of up to 2,000 characters, so a Digital Link URI with lot and serial fits.
4. Resolver rules. A GS1-conformant resolver may strip lot and serial and answer on the GTIN; lower levels inherit the GTIN's links (Resolver Standard 1.2.1). So the code on the product can be finer than your web pages: print serials now, serve one page per GTIN, add item pages later. See our resolver guide.
5. Back-ups. ESPR Article 10(4) and the detergent law (Article 21(12)(c)) require a back-up copy through a DPP service provider: at item level, one per passport.
6. Personal data. No customer personal data in an ESPR passport without explicit consent (Article 10(1)(e)); the JRC flags data-protection issues for item-level passports.

Enrolment and upload are covered in our registry guide.

What drives the cost of each level?

The JRC calls digital product passport granularity a key cost driver: moving from model to item level adds data generation, more frequent updates, governance work and identification or tracking infrastructure (§2.2.4.2). Brief finance and suppliers with this list, priced line by line:

Encode finer than required now? GS1 allows the code to carry a finer identifier than your act requires, and resolvers can ignore the extra qualifiers. Where a line already prints variable data, adding a lot costs little; where it would force a new printer, wait for your act.

Walkthrough: an e-bike maker in Aveiro (hypothetical)

Take a hypothetical e-bike maker in Aveiro, Portugal, with two lines and two different answers on digital product passport granularity. All figures are invented for the example.

Line A: 12,000 battery packs a year, item level by law. For the data chain behind these passports, see our battery passport guide.

• One item. 10,800 bikes take one pack each. 600 touring bikes take two packs that share one battery management system (BMS) and work as one battery; the Commission's non-binding battery FAQ (Q3.2) treats that as one battery with one passport. The year needs 11,400 passports, not 12,000.
• Identifier. One GTIN per battery model (three models), plus a serial from the Aveiro range: numeric, no leading zeros. A QR code with /01/{GTIN}/21/{serial} is laser-marked on each battery; the cell lot sits in a linked batch record.
• Data. Composition, capacity, lifetime and dismantling data come from three model records. Per battery, the end-of-line test supplies performance values and the status "original".
• Registration. About 950 passports a month means ten files of at most 100. IT scripts ten validated uploads a month and earmarks the API work.

Line B: 40 cycling-jersey models, about 60,000 jerseys a year, level not yet set.

• Level. The textile delegated act, 2027 (expected), will set the digital product passport granularity for apparel.
• Matrix result. On the digital product passport granularity matrix, only variability reads B (dye lots); repair, counterfeiting and life-cycle read M.
• Printer. Care labels already come off a thermal transfer printer that prints sizes per order. Adding /10/{lot} to /01/{GTIN} is a template change, not new equipment, so rule 3 gives batch. The resolver serves one page per GTIN.
• Record counts. 40 models × about 6 dye lots a season × 2 seasons ≈ 480 batch records a year, against 60,000 at item level and 40 at model level.
• If the act lands at item level. The template gains /21/{serial}, and records go from about 480 to 60,000 a year. That is the line in the cost table to price now.

Three numbering counterfactuals.

• Serials restart at 1. If the Aveiro plant and a contract assembler both started at 1, two batteries would share one GTIN plus serial. Both codes would open one passport, and one bike's service update would land on the other's record.
• A lot code without a year. A day-of-year lot 245 comes back in 2027, so withdrawing one dye lot would also hit next year's jerseys.
• A stripped zero. If the jerseys later move to item level with RFID swing tags, a label serial 004711 stored as 4711 on a 96-bit tag gives one jersey two identifiers. Serials without leading zeros avoid it.

Edge cases: what if your products do not fit the table?

Edge cases where digital product passport granularity needs a closer look:

• Imported cells or modules. Assembled into a battery in the EU, they are normally not the finished battery that needs the passport (non-binding battery FAQ Q3.4).
• Several plants or contract manufacturers. Batch or item digital product passport granularity breaks if two sites issue the same numbers: give each site its own lot and serial range, as in the policy template above.
• Remanufactured items. A new passport links to the original (ESPR Article 11(d); batteries, Article 77(7)). A simple battery repair needs no new passport, according to the FAQ.
• Online listings and dealer requests. Dealers and marketplaces can ask for a free digital copy of the data carrier or identifier within five working days (ESPR Article 10(3)). The JRC adds that item-level products should still show model-level information online: keep a GTIN-only link per model.
• Made-to-order products. GS1's provisional Made-to-Order GTIN, AI (03), is not approved for retail, online marketplaces included. Before printing it on anything sold through retail or a marketplace, ask your GS1 member organisation which identifier to use.

Zoom out: which pending decisions could change your level?

Settled: ESPR Articles 9–11 and Annex III; IR 2026/1778 Article 8; item-level battery passports from 18 February 2027; the CPR product type; model level for toys and detergents; GS1 General Specifications 26.0 and Resolver Standard 1.2.1.

EN 18219 (unique identifiers) and EN 18220 (data carriers) are cited as harmonised standards in the Official Journal (Implementing Decision (EU) 2026/1736). Read them before you freeze your numbering.

Pending, and what to do now:

The rules of digital product passport granularity are law; the level for most ESPR products is not. Number so you can go finer without new artwork.

What should you decide about digital product passport granularity this quarter?

Seven decisions, each with an owner, fix your digital product passport granularity plan:

Whatever digital product passport granularity you land on, keep a model-level link ready for listings and dealer requests.

Make test codes at each level with the free GS1 Digital Link QR generator: no signup, and it runs in your browser. Passmith also has a free plan.

Further reading: What is a digital product passport? · DPP implementation in 8 steps · DPP registry · GS1 Digital Link resolver · Battery passport

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